PROTECTION OF YOUR PERSONAL DATA
This privacy statement provides information about the processing and the protection of your personal data.
Processing operation: ‘The EU Delegation’s www.eu4georgia.ge website’
Data Controller: The Delegation of the European Union to Georgia, Google Corporation.
Record reference: [DPR-EC-02019]
The Delegation of the European Union to Georgia (hereafter ‘the Delegation) is committed to protect your personal data and to respect your privacy. The Delegation collects and further processes personal data pursuant to Regulation (EU) 2018/1725 of the European Parliament and of the Council of 23 October 2018 on the protection of natural persons with regard to the processing of personal data by the Union institutions, bodies, offices and agencies and on the free movement of such data (repealing Regulation (EC) No 45/2001).
This privacy statement explains the reason for the processing of your personal data, the way we collect, handle and ensure protection of all personal data provided, how that information is used and what rights you have in relation to your personal data. It also specifies the contact details of the responsible Data Controller with whom you may exercise your rights, the Data Protection Officer and the European Data Protection Supervisor.
The information in relation to processing operation ‘The EU Delegation’s www.eu4georgia.ge website’ undertaken by the Delegation of the European Union to Georgia is presented below.
WHY AND HOW DO WE PROCESS YOUR PERSONAL DATA?
Purpose of the processing operation: The Delegation of the European Union to Georgia collects and uses your personal information for the purposes of the visibility and promotion of EU-funded projects and programmes in Georgia through publication of news and success stories about the EU-funded programmes and projects and EU-related opportunities in in Georgia.
The purpose of the data processing is to:
- Manage and improve EU project communication
- Improve website user experience and analyse webpage traffic (Google Analytics)
All data processing is transparent and abides by the principle of users opting-in/out, and allowing the data they provide to be used for specific purposes.
Your personal data will not be used for an automated decision-making, including profiling.
ON WHAT LEGAL GROUND(S) DO WE PROCESS YOUR PERSONAL DATA
We process your personal data because the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Union institution or body (Article 5 (a) of Regulation (EU) 2018/1725);
The basis for the processing is laid down by the following Union law: Article 11 of the consolidated European Treaty on the European Union states: “The institutions shall, by appropriate means, give citizens and representative associations the opportunity to make known and publicly exchange their views in all areas of Union action. The institutions shall maintain an open, transparent and regular dialogue with representative associations and civil society”.
Article 21(1) of the Treaty on European Union (TEU): overall mandate and guiding principles in the field of EU development cooperation; Articles 4(4) and 208 to 211 of the Treaty on the Functioning of the European Union (TFEU).
In addition, the processing is necessary for the fulfilment of The Delegation’s obligation to ensure visibility of the Union’s financial support, as stipulated in Article 4(5) of Regulation (EU) No 236/2014 of the European Parliament and of the Council of 11 March 2014 laying down common rules and procedures for the implementation of the Union’s instruments for financing external action, OJ L 77, 15.3.2014.
Where data are not marked as mandatory, DG NEAR processes your personal data based on your consent (Article 5 (d) of Regulation (EU) 2018/1725). All data processing is transparent and abiding by the principle of users’ opting-in/out, and allowing the data they provide to be used for specific purposes.
We do not process special categories of personal data (Article 10 of the Regulation (EU) 2018/1725.
WHICH PERSONAL DATA DO WE COLLECT AND FURTHER PROCESS?
In order to carry out this processing operation the Delegation of the European Union to Georgia collects the following categories of personal data:
- Visitor’s web browser configuration
- IP address
- Clicked websites
- Time spent on sites
This data provides an understanding of authenticated activity on the website.
WHAT ARE COOKIES?
Cookies are pieces of text generated by the web services that a user has visited; these text files can be set on the users’ devices by the website they are currently visiting (“first party persistent cookies”) or by a different website to the one they are currently visiting (“third party cookies”).
To facilitate the functioning of our website we may – subject to visitors’ consent – place small data files called cookies on your device. They enable the website to remember your actions and preferences (such as login, language, and font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.
Different types of cookies will be in use:
- First party persistent cookies
- Technical session cookies
- Third party cookies (including the Google Analytics cookies)
- Third party cookies from the Share widget
On this promotional website the following types of cookies are used: ‘first-party persistent cookies’, and ‘session cookies’.
‘First party persistent cookies’ enable the tracking of the following information about the visitors to our website:
- IP address (anonymised)
- Location: country, region, city, approximate latitude and longitude (Geolocation)
- Date and time of the request (visit to the site)
- Title of the page being viewed (Page Title)
- URL of the page being viewed (Page URL)
- URL of the page that was viewed prior to the current page (Referrer URL)
- Screen resolution of user’s device
- Time in local visitor’s time-zone
- Files that were clicked and downloaded (Download)
- Links to an outside domain that were clicked (Outlink)
- Pages generation time (the time it takes for webpages to be generated by the webserver and then downloaded by the visitor: Page speed)
- Main language of the browser being used (Accept-Language header)
- Browser version, browser plugins (PDF, Flash, Java, …) operating system version, device identifier (User-Agent header)
- Language of the visited page
- Site Search
The collected data will not be shared with any other organisations for marketing, market research or commercial purposes. Moreover, the abovementioned data cannot be used to identify a particular visitor.
‘First party persistent cookies’ are created by this website and enable:
- proper functioning of the website;
- the collection of statistics to improve website functionalities – for this purpose, the website uses Google Analytics (more information is provided below);
- social media sharing functions.
‘First party persistent’ cookies expire after thirteen months (13), after which they are automatically removed from the users’ device.
‘Technical Session’ cookies do not contain any data – they are placed for the duration of a user session (time spent browsing the website). These cookies are necessary to keep the visitor’s choice selection when the website is accessed. Once the visitor leaves the website, the session cookie is deleted.
‘Third party cookies’ (including the Google Analytics cookies) are detailed below in section 6.
‘Third party cookies’ from the Share widget are placed on the computer – if the user opted-in – in order to allow users to share content on social media.
The website does not set cookies with the display of links to our social media when you are browsing our website.
When the website is accessed first, the website visitor is provided with a choice to accept (“OK, I agree”) or refuse (“Decline cookies”) the placement of cookies.
Accept cookies: By clicking this option, the visitor gives consent to the placement of all the cookies for the:
- Optimal functioning of the website
- Social media sharing function
- Collection of statistics
Decline cookies: By clicking this option, the visitor does not give consent to the placement of any of the abovementioned cookies. In this case, only a session cookie is placed; this is a technical cookie, the main purpose of which is to remember the visitors’ selection choice. This cookie is placed for the duration of a user session (time spent browsing the website) and will automatically be deleted when said session expires. Choosing not to accept cookies does not hinder your navigation experience on the website.
In case a visitor has opted-in to the placement of cookies, it is always possible to change this decision and opt-out. In order to opt-out, visitors need to delete all the cookies from their browser. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities may not work.
To learn about how to clear cookies in different browsers, visit: https://www.aboutcookies.org/
DO NOT TRACK OPTION
Do Not Track is a technology that enables visitors to opt out from being tracked by websites for whatever purpose, including the use of analytics services, advertising networks and social platforms. You can enable the ‘Do not track’ option directly in your web browser. Google Analytics will not track users who have enabled this option in their web browsers.
The website uses Google Analytics in order to track the information of visitors described above. For this purpose, the abovementioned collected data are transmitted to Google Inc. The IP addresses of visitors are anonymised by the website prior to their transmission to Google Inc; this protects the anonymity of the visitors that have opted for the full website functionalities.
Google complies with the EU-US Privacy Shield Framework and more information on its certification can be found here.
Furthermore, Google, including Google Inc. and its wholly-owned US subsidiaries, has certified that it adheres to the relevant Privacy Shield Principles, including for Google Analytics.
More information on the EU-US Privacy Shield can be found on this page.
Google Analytics has implemented a data retention control feature. This feature provides website owners with the flexibility to define a retention period for the data stored within the Google Analytics account. The defined retention period is 26 months; any data beyond this period is deleted from Google servers.
HOW LONG DO WE KEEP YOUR PERSONAL DATA?
The Delegation of the European Union to Georgia only keeps your personal data for the time necessary to fulfil the purpose of collection or further processing.
Data will be kept as long as the data subject is registered and for as long as the website operates as a tool of EU Delegation’s promotion policy. Some parts of the data might be kept for a longer period where stipulated by financial authorities (10 years in case of financial transactions) or for auditing purposes (usually 7 years). Data will be automatically removed at the end of the respective period or when no longer needed.
HOW DO WE PROTECT AND SAFEGUARD YOUR PERSONAL DATA?
All personal data in electronic format (as per chapter 4 above) are stored either on the servers of the European Commission or of its contractors. All processing operations are carried out pursuant to the Commission Decision (EU, Euratom) 2017/46 of 10 January 2017 on the security of communication and information systems in the European Commission.
The Delegation’s contractors are bound by a specific contractual clause for any processing operations of your data on behalf of the Delegation, and by the confidentiality obligations deriving from the transposition of the General Data Protection Regulation in the EU Member States (‘GDPR’ Regulation (EU) 2016/679.]
In order to protect your personal data, the Delegation has put in place a number of technical and organisational measures. Technical measures include appropriate actions to address online security, risk of data loss, alteration of data or unauthorised access, taking into consideration the risk presented by the processing and the nature of the personal data being processed. Organisational measures include restricting access to the personal data solely to authorised persons with a legitimate need to know for the purposes of this processing operation.
The collected personal data and all information related are stored on the servers of the Processors during the implementation and the maintenance of the website.
Personal data in electronic form: access to your personal data, as well as any other information collected in the website is exclusively provided through an identification system with password, accessible to a restricted number of users, without prejudice of a possible future transmission of these data to the bodies charged with the control and inspection of the Delegation’s activities in conformity with EU law. These users are the Units of the Delegation, as well as officially contracted external companies.
WHO HAS ACCESS TO YOUR PERSONAL DATA AND TO WHOM IS IT DISCLOSED?
Access to your personal data is provided to the Delegation staff responsible for carrying out this processing operation and to authorised staff according to the “need to know” principle. Such staff abide by statutory, and when required, additional confidentiality agreements.
The Data Controller and its Processors have access to your personal information. The Processors are either:
- Staff of the Delegation’s contractor in charge of the communication services, which manage the collected personal data and conduct ad hoc satisfaction surveys;
- staff of the Delegations contractors providing web services for the ‘EU Delegation eu4georgia.ge website’ (such as website design, website hosting including cloud services etc.).
Further access may be granted on a need to know basis to EU Institutions (including the Commission, EU Delegations in third countries etc.).
No personal data is transmitted to parties, which are outside the recipients and the legal framework mentioned. The data are solely collected and further processed for the specific purposes mentioned in this privacy statement and shall not be used for any other purpose.
Any recipient shall be reminded of its obligation not to use the data received for other purposes than the one for which they were transmitted.
WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?
You have specific rights as a ‘data subject’ under Chapter III (Articles 14-25) of Regulation (EU) 2018/1725.
You have the right to object to the processing of your personal data, which is lawfully carried out pursuant to Article 5(1)(a) on grounds relating to your particular situation.
You have consented to provide your personal data to Delegation of the European Union to Georgia for the present processing operation. You can withdraw your consent at any time by notifying the Data Controller. The withdrawal will not affect the lawfulness of the processing carried out before you have withdrawn the consent.
You can exercise your rights by contacting the Data Controller, or in case of conflict the Data Protection Officer. If necessary, you can also address the European Data Protection Supervisor. Their contact information is given under Heading 9 below.
Where you wish to exercise your rights in the context of one or several specific processing operations, please provide their description (i.e. their Record reference(s) as specified under Heading 10 below) in your request.
- The Data Controller
If you would like to exercise your rights under Regulation (EU) 2018/1725, or if you have comments, questions or concerns, or if you would like to submit a complaint regarding the collection and use of your personal data, please feel free to contact the Data Controller, Delegation of the European Union to Georgia, using the functional mailbox firstname.lastname@example.org
- The Data Protection Officer (DPO) of the Commission
You may contact the Data Protection Officer (DATA-PROTECTION-OFFICER@ec.europa.eu) with regard to issues related to the processing of your personal data under Regulation (EU) 2018/1725.
- The European Data Protection Supervisor (EDPS)
You have the right to have recourse (i.e. you can lodge a complaint) to the European Data Protection Supervisor (email@example.com) if you consider that your rights under Regulation (EU) 2018/1725 have been infringed as a result of the processing of your personal data by the Data Controller.
WHERE TO FIND MORE DETAILED INFORMATION?
The Commission Data Protection Officer (DPO) publishes the register of all processing operations on personal data by the Commission, which have been documented and notified to him. You may access the register via the following link: http://ec.europa.eu/dpo-register.
This specific processing operation has been included in the DPO’s public register.